1. Fluoride Exposure from Pesticides: The Case Against SULFURYL FLUORIDE Michael Connett, FAN 2nd Citizens’ Conference on Fluoride July 30, 2006

2. Which Foods Can be Fumigated with Sulfuryl Fluoride?

3. Dried Eggs 900 ppm

4. Wheat (flour & germ) 130 ppm

5. Oat (flour & rolled) 75 ppm

6. Legumes (57 types) 70 ppm

7. Processed Foods (ALL) 70 ppm

8. Barley (bran, flour, pearled) 45 ppm

9. Corn (meal & flour) 30 - 35 ppm

10. Other Tolerances 70 ppm: Herbs & Spices (135 types) 40 ppm: Wheat (bran & grain) 40 ppm: Millet (grain) 45 ppm: Rice (flour) 40 ppm: Coconut 40 ppm: Cattle (meat, dried) 31 ppm: Rice (bran) 25 ppm: Rice (wild grain & polished) 25 ppm: Oat (grain) Allowable levels of fluoride “in or on” food:

11. 20 ppm: Cocoa bean 15 ppm: Peanuts 15 ppm: Coffee 15 ppm: Barley (grain) 10 ppm: Corn (grain) 10 ppm: Tree Nuts (14 types) 7 ppm: Raisin 5 ppm: Cheese 5 ppm: Powdered Milk 3 ppm: Dried Fruit Other Tolerances (cont.)

12. How Much Fluoride Will We Ingest From Fumigated Foods?

13. The Daily Dose for adults 0.67 mg/day EPA’s estimate for the average exposure to fluoride from SF 2nd Largest Daily Source of Fluoride (EPA 2006)

14. The Daily Dose for children 0.08 - 0.57 mg/day EPA’s estimate for a child’s average exposure to fluoride from SF 2nd Largest Daily Source of Fluoride (EPA 2006)*

15. The Daily Dose for children AgeAvg. Dose from SF < 1 yr0.08 mg/day 1-2 yrs0.26 mg/day 3-5 yrs0.48 mg/day 6-12 yrs0.57 mg/day EPA, Final Health Risk Assessment, January 2006

16. How Did this Happen? EPA’s Risk Assessment

17. Food Quality Protection Act (FQPA) “When setting new tolerances, or reassessing existing tolerances or tolerance exemptions, EPA must now focus explicitly on exposures and risks to children and infants. EPA must, 1) explicitly determine that the tolerance is safe for children; 2) consider the need for an additional safety factor of up to ten-fold to account for uncertainty in the data base relative to children unless there is evidence that a different factor should be used; and 3) consider children's special sensitivities and often unique exposure patterns to pesticides.” -- EPA, Federal Register, January 31, 1997

18. Did EPA: “explicitly determine that the tolerance is safe for children?” FQPA Requirement

19. For its risk assessment, EPA used the “MCLG” (Maximum Contaminant Level Goal) Set by EPA’s Office of Water in 1985. Vigorously criticized by Natural Resources Defense Council (NRDC) and EPA Headquarters Union. An Adult-Based Health Standard (MCLG)

20. “there was a consensus that mottling or pitting of teeth could represent as yet unknown skeletal effects in children and that severe dental fluorosis per se constitutes an adverse health effect that should be prevented.” -Surgeon General’s Panel on the Non-Dental Effects of Fluoride (1983) A glimpse into the history…

21. Assumption #1: Severe Dental Fluorosis is not an adverse health effect Problems with MCLG

22. Assumption #2: Crippling Skeletal Fluorosis is the ONLY adverse effect fluoride has on bone. Problems with MCLG

23. Assumption #3: 20 mg/day is the lowest dose that could harm human health. Problems with MCLG

24. Assumption #4: Fluoride has NO effect on ANY soft tissues (at less than 50 ppm in water). Problems with MCLG

25. 20 mg/day considered the “lowest observable adverse effect level” for crippling fluorosis. A safety factor of 2.5 used, resulting in a safe dose of 8 mg/day. Assuming people drink 2 liters of water a day & assuming no other sources of fluoride, EPA set the MCLG at 4 mg/L (8 mg/day / 2 liters = 4 mg/L). Basis of MCLG

26. Converting MCLG into a “Reference Dose” EPA Pesticide Division has traditionally derived its “reference dose” from the MCLG as follows: “Safe” dose = 8 mg/day (2 liters of 4 ppm) The average adult weighs 70 kilograms (kg) 8 mg divided by 70 kg = 0.114 mg/kg Reference Dose = 0.114 mg/kg/day (milligrams per kilogram of bodyweight per day)

27. Did EPA: “consider the need for an additional safety factor of up to ten-fold to account for uncertainty in the data base relative to children”? FQPA Requirement

28. Reasons why Additional Safety Factor for Children would be Appropriate Exposure during childhood causes severe dental fluorosis. Children’s bones are probably more, not less, susceptible to fluoride damage (Surgeon General 1983). New research (published after MCLG was adopted) has raised additional health concerns from childhood exposure: Neurotoxicity (Xiang 2003) Osteosarcoma (Bassin 2006) Kidney damage (Xiong 2006) Endocrine effects (Lin Fa-Fu 1991)

29. So, what happened?

30. DOW Agrosciences (2002): “These levels of dietary exposure in combination with the potential dietary exposures that the proposed uses of ProFume would represent are considerably lower than the USEPA MCLG for fluoride of 0.114 mg/kg/bwt/day." http://www.fluoridealert.org/pesticides/sulfuryl.f.fr.Feb.15.2002.htm

31. EPA (2002): "In consideration of the proposed temporary tolerances for walnuts and raisins, the Agency used the maximum concentration limit goal (MCLG) of 4.0 ppm (0.114 mg/kg/day).” http://www.fluoridealert.org/pesticides/sulfuryl.f.fr.Feb.7.2002.htm

32. Ooops…. Fluoride Exposure (mg/kg) Levy (2003) Age (mo)90th%95th%Max 1.50.1590.1880.401 60.1270.1470.343 120.0860.1030.272 240.0980.1280.298 320.0980.1150.223 RED = Exceeds EPA’s reference dose (0.114 mg/kg)

33. Making a bad standard, worse After it became apparent that some children are already exceeding 0.114 mg/kg, EPA increased the allowable dosage for children.

34. Increasing the Safe Dosage < 2003January 2004July 2005 AgeInitial Safe Dosage 2nd Safe Dosage 3rd Safe Dosage < 1 yr old0.114 mg/kg0.571 mg/kg1.14 mg/kg 1-2 yrs old0.114 mg/kg0.308 mg/kg0.615 mg/kg 3-5 yrs old0.114 mg/kg0.182 mg/kg0.364 mg/kg

35. Making a bad standard, worse The allowable dosage is now 10 times higher for infants than for adults

36. Problems with New “Safe Dosage” Not based on new data or research. Contradicts key component (SMCL) of EPA’s safe drinking water standard for fluoride. Dwarfs the dose that causes severe dental fluorosis. Exceeds the dosage (0.45 mg/kg/day) which increases bone fractures in less than 2 years in clinical trials with adult osteoporosis patients.

37. Did EPA: “consider children's… often unique exposure patterns”? FQPA Requirement

38. EPA’s “Conservative” Estimate of Toothpaste Ingestion "Despite the variability in the estimates of ingested toothpaste, maximum exposures to fluoride observed in those studies appear to converge to approximately 0.3 mg/day (assuming 2 brushings per day). The exposure estimates range from 0.004 to 0.04 mg/kg/day and should be considered conservative in nature..." EPA, Health Risk Assessment, January 2004

39. Fluoride Ingestion from Toothpaste Published Data (2 brushings, 1000 ppm F) Age (yrs)Avg IntakeMax IntakeStudy 20.66 mg/dayn/a Naccahe ‘87 2.50.54 mg/day1.66 mg/day Bentley ‘99 2 - 30.56 mg/dayn/a Simard ‘84 2 - 40.6 mg/day>1.46 mg/d Barnhart ‘76 3 - 60.76 mg/day2.3 mg/day Hargreaves ‘75 30.36 mg/dayn/a Naccahe ‘85 40.78 mg/dayn/a Simard ‘84 40.26 mg/day0.6 mg/day Ericsson ‘74 50.44 mg/dayn/a Simard ‘84 Red: Exceeds EPA’s “Conservative Estimate” (0.3 mg/day)

40. Other Problems with EPA’s Risk Assessment

41. Other Problems with EPA’s Risk Assessment Under-estimated fluoride exposure among adults by failing to account for high-end water consumers. Did a superficial analysis of acute fluoride toxicity by only considering the dose that kills, vs the dose that causes symptoms (nausea, vomiting, etc) Violated procedural requirements in a manner that restricted input and participation from concerned parties. And more: See FAN’s petition to EPA for further details

42. Implications of NRC Report

43. The increases in allowable childhood dosages will need to be rescinded. A lower MCLG will necessitate a lower reference dose across the board (both children and adults). Since many Americans are already exceeding current reference dose, many more will exceed the new, lower one.

44. Q & A

45. The Reference Dose EPA (2002): “EPA has determined that the dose to be used for risk assessment for exposure to fluoride is 0.114 mg F/kg/day, per the 1996 Cryolite RED. This value is used for all population subgroups..." http://www.epa.gov/fedrgstr/EPA-PEST/2002/April/Day-24/p9655.htm